Guideline of measures of client due diligence
In accordance with ACRA’s regulations, Healy Consultants implements stringent due diligence checks on all our Clients, to make sure that our business setup and other corporate services do not facilitate money laundering, financing of terrorism and other illegal activities prohibited by Singapore and foreign Governments.
Please read this page for an overview of due diligence procedures to be implemented by all Healy Consultants’ employees. Aidan Healy, our compliance officer Cai Xin and your department heads are always there to answer your queries.
Why do we implement due diligence checks
- Because this is the law – all corporate services providers must implement risk based assessments of their Clients;
- Because this protects Healy Consultants and its employees – If we assist a Client to form a company or open a bank account thereafter used for illegal purposes, we can be punished with fines and prison time by the Singapore Government;
- Because this protects the interest of Healy Consultants’ Clients – Our Clients are honest, law abiding business people and entrepreneurs who do not want to be associated with criminals and Firms assisting criminals.
How do we implement due diligence checks
- When you expect to close a sale, always refer to the client risk assessment section for an assessment calculator to help you to determine the risk level of your potential Clients. If the result does not make sense to you, indicate it to Aidan, Cai Xin or your department head;
- Validate your risk assessment level with Cai Xin, your department manager and Aidan Healy. If the three of them disagree, Cai Xin’s assessment always prevails;
- Choose the correct due diligence checklist for each Client according to i) his/her risk level and ii) the type of risk(s) our Firm expects to face;
- Approval for the content of the checklist must be approved by i) Cai Xin and your department head for medium risk Client ii) the same + Aidan for high risk Clients;
- At least once every week, remind your Client of the need to email you scans of the pending due diligence documents. Originals to follow as soon as possible and before corporate bank account opening for intermediate and high risk Clients;
- If a Client is declining to provide some of the due diligence documents, you can ask Cai Xin to contact the Client to request the same (her email to always be approved by Aidan);
- If the Client continues to refuse to provide due diligence documents, we will unilaterally terminate the engagement. No refund for the Client and no penalty for the CRO;
- Before 75% engagement is complete, Cai Xin need to signs off Client files. Approvals needed to do so are as below:
- Cai Xin for low risk Clients;
- Simon + Cai Xin for medium risk Clients;
- Aidan + Cai Xin + Simon for high risk Clients.
Clients risk assessment and checklists
Clients risk assessment calculator
Select Yes / No to get the total risk points and risk level of a Client at end of this table:
Other due diligence measures in place
- Every Monday morning, Cai Xin will send CRO directors a weekly report form (see below) to complete. Please revert this form to Cai Xin by 5 PM. It will be the task list for Cai Xin to make sure complete quality due diligence is timely collected during the week;
- Every day, Cai Xin will send at least one email to CRO i) outstanding due diligence to sign off a file or ii) reminding CRO to re-ask their Clients’ for due diligence documents;
- Every week, for existing clients resisting to giving us the due diligence we requested, Cai Xin emails a new Client asking them directly and harshly for outstanding due diligence;
- Every six months, the company organizes a seminar including i) a reminder of due diligence policies in place ii) problems encountered by staff and solutions to make the dd process smoother for everyone and iii) Q&A from the staff.
|Team Leader||Client name||Risk level||Co reg date||Bank ac opening date||Bank signatory has e-banking tokens?||Company kit sent to Client?|
|Karen||Low||1 Feb||15 February||Yes or no||Yes or no|
Penalties if a Healy Consultants’ employees does not implement due diligence checks
- If an employee does not implement due diligence checks, the penalties (by order of gradation) are as follows:
- Gentle reminder from the compliance department or management;
- Face to face meeting with management to i) explain why the employee fails to implement due diligence checks and ii) find together solutions;
- Employee warning in writing.
- If three employee warnings are received for not implementing due diligence policies, Healy Consultants will conduct a meeting with the employee, Aidan Healy, HR and the department head and can decide to terminate employment for gross misconduct, in accordance with the employment contract of the employee.